On November 22, 2016, the U.S. Environmental Protection Agency (EPA) issued a notice in the Federal Register of an opportunity to comment on petitions requesting EPA initiate a rulemaking process to reconsider its regulations that impose the obligation for compliance with the Renewable Fuel Standard (RFS) annual standards on gasoline and diesel fuel refiners and importers, as well as on EPA’s proposed denial of the petitions. As the notice states, EPA is looking for petitioners to demonstrate the change in the point of obligation would improve the effectiveness of the RFS program, thus warranting the substantial disruption and increased complexity it would bring to the program. According to EPA, the petitioners have not demonstrated that the change would result in increased use of renewable fuels. EPA is seeking comments on the submitted petitions and its proposed denial of the requests to initiate rulemaking. EPA requests that comments address the likelihood of a change in the point of obligation resulting in a significant increase in production, distribution, and use of renewable fuels. Comments are due January 23, 2017.

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